Secretary Matthew Beaton
Executive Office of Energy and Environmental Affairs, Attn MEPA Office
Alexander Strysky EEA#15278
100 Cambridge St. #900 Boston Ma. 02114
Re: Allston I-90 Interchange DEIR
Date: Feb 1, 2018
Dear Secretary Beaton,
We City Councilors from Newton are writing to express our grave concern regarding the Massachusetts Department of Transportation’s (MassDOT) Draft Environmental Reivew (DEIR) for the Allston Interstate 90 Interchange project. MassDOT’s proposed project timeline will have a disastrous impact on thousands of our constituents during the 6 years of construction and beyond. The concerns raised in this letter pertain to several domains; disruption during construction, the cost of the project, and long term environmental impact to our community. As this project is proposed to be funded in part by tolls our consitutients pay, we feel it is important to make sure that the road reconstruction has the least impact possible on city, and is fiscally and environmentally responsible. It appears that MassDOT has overlooked outreach to the western suburbs, who are key stakeholders in this process. We are joininig the more than a dozen community and advocacy organizations who have been overseeing the planning of this project for several years to advocate for a more effective, affordable, and environmentally sound alternative to the proposed project.
Our concerns are as follows:
Worcester Line Impact During Construction
The Worcester Line is one of the busiest Commuter Rail corridors in the Commonwealth, yet the decision matrix between the three potential options for replacing the viaduct does not take into account the full impact to the Worcester Line. (It has a high level of detail for the impact to the non-revenue Grand Junction track, which does not serve any passenger rail traffic, but no commensurate detail for the Worcester Line impact.) MassDOT’s assumption is that the highway will be reduced to three lanes and that the Worcester Line will be reduced to one track. This is unacceptable to communities which have been fighting for decades for better train service. When the second track was finally put in to service in Allston last year, it led to significantly faster and more reliable service. Yet the DEIR assumes that a single-track bottleneck will be acceptable during construction, and does not analyze the differences between the proposals in this regard. This must be addressed, especially considering that the highway will have reduced capacity because of construction during this time.
Our legislative leaders and constituents have fought for decades for improvements to the Worcester Line, and now is not the time to renege on these improvements. We believe that the at-grade “ABC” alternative could be built with minimal disruption to Worcester Line service, while MassDOT’s viaduct option would require several years of strangled, single-track operation. This must be fully addressed as a major construction impact—on par with, if not ahead of the Grand Junction—in the final alternative decision, and a supplemental DEIR may be necessary to fully account for these impacts.
Traffic Modeling
The traffic model used by MassDOT makes several assumptions about transit ridership which are hard to reconcile with reality, resulting in automobile-centered development which increases traffic volume and congestion on the Turnpike. In the words of MassDOT and FMCB board member Monica Tibbetts-Nutt: “I straight up just do not believe this traffic analysis.” The model shows most traffic in 2040 in the development coming and going by car. Such a car-centric Allston will be one which requires more people to drive, adding to the already heavy traffic on the Turnpike. A reliable traffic model must be investigated to assure that 7 million square feet of new construction is not served chiefly by highway traffic and takes into account new connections in the Allston area to minimize any increase to congestion on the Turnpike. Such planning would also fly in the face our state-level emission goals, as well as Governor Baker’s commitment to the US Climate Alliance in support of the Paris Climate Agreement.
Cost Considerations
The Allston project is state-funded, and much of this money will come from the tolls Turnpike users pay every day. We believe it is imperative that the state make a fiscally prudent choice in selecting a final alignment for the project. MassDOT’s original highway viaduct alternative is significantly more expensive than the at-grade “ABC” alternative (by nearly $100 million dollars, although simplifying construction staging for this alternative may bring costs down further). Furthermore, the DEIR does not take in to account any life cycle costs for the viaduct. The current viaduct costs $800,000 annually to keep in a safe, usable state. A new viaduct would cost less to maintain at first, but it would still cost more to maintain—and have a shorter life span—than an at-grade alternative.
Environmental Impact
We are in agreement with the Charles River Conservancy, which believes that this highway project should also create the new Worcester Line commuter rail stop dubbed West Station, a new bus route over the highway to connect Harvard Square, North Allston, West Station, Boston University, Comm Ave, and Longwood. “Thinking more broadly, cities all over the world are re-imaging how their urban rivers can enhance their lives...It can correct one of the worst strips of the entire Charles River.” An at grade highway makes possible improved bus and rail transit – a goal to reduce our dependence on automobiles that we all believe in, and make bike and pedestrian enhancements as well.
Recommendation:
We believe that an at-grade alternative—already the least expensive to construct, according to MassDOT—is the best path forward. We call on the state to provide a full life-cycle cost estimate for each alternative, to make sure that the citizens of the Commonwealth, and the toll payers on the Turnpike in particular, do not overpay for an unnecessarily complex highway.
Thank you,
Susan Albright, Andreae Downs